IRSE Sept 08.indd

SECTION NEWS
IRSE
A Report from Deep in
the Heart of Texas
by Wim Coenraad & Joe Noffsinger
On May 20 2008, coinciding with the Rail
Systems Suppliers Inc (RSSI) 1 2008
Exhibition in Grapevine, Texas, the IRSE
North American Section (NAS) organised
its first seminar. The subject of the
seminar, “Lessons Learned in Safety
Approvals” was chosen to introduce a new
set of US Federal Railroad Administration
(FRA) practices on this subject. The IRSE
President and immediate past president as
well as the Chief Executive attended the
seminar and had the pleasure of spending
a few days in the company of the local
committee and IRSE members.
Amongst the speakers were IRSE
President Alan Fisher, giving a version of
his presidential address to the NAS as well
as immediate past President Wim
Coenraad, invited to speak on European
acceptance practices. It also allowed Wim
to compensate for the fact he had not
been able to visit the NAS earlier during his
own presidential year.
In Grapevine's Gaylord Texan Resort
and Convention Center, a bit of a “Disney
world “ style rendition of the old Texas,
IRSE members and RSSI attendants
gathered and listened to speakers
representing an industry cross section,
including: the FRA, Amtrak, Movares, New
Jersey Transit, and Systra Consulting.
It was interesting to note that the
regulator FRA has tried to avoid being
prescriptive in narrowly enforcing any
single set of standards, such as the EN's
we use in Europe. They have the view that
“The System/Product Is At Least As Safe
As What Was There Before” and “The
Railroad and Vendors Specify How They
Meet the Objective”. The FRA does not
mandate a solution, nor does it perform
certification or mandate any techniques or
standards, but instead it intends to
approve the documentation submitted by
the Railroads, evaluate the adequacy of
the analysis and monitor compliance of the
stated safety argument.
As the FRA can only regulate the
Railroads, i.e. the infrastructure &
Setting up for the first NAS Technical Forum
Left to Right: Wim Coenraad (Movares),
Mark Hartong (FRA), Kendrick Bisset (IRSE NAS)
(picture Joe Noffsinger).
operators (in North America they are
generally the same entity), the burden of
delivering the acceptance files is on the
railway, and they will have to work out
development of the comprehensive
documentation with their suppliers. Whilst
this may go some way towards alleviating
the fears of being strangled in “European
style CENELEC red tape”, there is the
possibility that this lack of guidance might
very well lead to scope creep, and ever
increasing expectations on the side of the
regulator. It is quite possible that each
new set of safety case documentation will
set a standard or a level of expectation for
the next ones. If nothing else, EN 50129
does at least give a framework of what a
safety case is (and therefore also what it
does not have to be). The fact that some
us do not know how to interpret that
cleverly, but would rather follow it to the
letter instead of following the “good is
good enough” criterion, cannot be blamed
on the standard. Also, it will be interesting
to see how North American suppliers will
deal with prior acceptance for platforms
and re-use/cross-acceptance of product
safety cases in the absence of some sort
of common reference. The rules
specifically endorse CENELEC norms as
one of the acceptable choices when the
railway designates the standard to be
applied for a new system. AREMA, IEEE,
are also included on the list, but any other
standard can be used where the railway
can prove its applicability and
appropriateness to FRA.
The recent safety approval requirement
is now codified in the US Code of Federal
Regulations 2 , and is the result of a six-year
process of “negotiated rulemaking” that
included stakeholders of the regulator,
railways, union labour representatives, and
suppliers. While not mandating a
particular technical standard, the rule is
very specific on the process steps to
approval, and the required contents of a
filing for approval of a new system. The
overarching burden is to demonstrate that
the safety of operation on a line will not be
adversely impacted by a new product or
system. There is a catch, though. The
analysis must include anticipated future
operations, including such things as train
density, increased passenger operations or
hazardous material cargo, and any other
operational changes. To date FRA has
taken a pragmatic approach, and is
coaching applicants through the process
as both parties learn how to apply the
requirement.
Amongst other business, such as the
NAS AGM and election of committee
members, also concluded during the
afternoon, the NAS was able to launch its
new textbook “Introduction to North
American Railway Signaling”, which is a
worthy addition to the IRSE’s line of
textbooks.
Footnotes
1 Railway Systems Suppliers
Incorporated (RSSI) is a trade organisation
for North American railway signal and
communications suppliers. The primary
mission is producing the annual exhibition,
focused exclusively on S&C products and
services. The 2008 Exhibition represented
143 exhibiting companies with a
registered attendance of 1323.
http://www.rssi.org
2 The new rule is in Volume 49, Part
236, subpart “h” of the Code of Federal
Regulations and is available with a
detailed background explanation to those
interested at
http://edocket.access.gpo.gov/2005/
pdf/05-3955.pdf
IRSE
NEWS Issue 137 September 2008 31